BillHustonBlog: Following the TAINT in federal pipeline regs

Following the TAINTED TRAIL in federal pipeline regs

Here is a new chart I am working in.
I submit it here for your review.

Please comment if you see errors or omissions.
DRAFT

So first thing this shows is basically how "High Consequence Areas" are calculated
by Federal Regulations. These regs are EXTREMELY complex and

What I mean by a "taint" is either a clear error in a formula or model,
or else what I would call an irresponsible, and non-scientific under-valuation
of risk which places human lives in jeopardy.

So there idea is that there are 3 sources of TAINT in Federal Pipeline Safety Regs.
This attempts to map it out.

Population Density
(which inputs into both Class determination and also HCAs)

What might be reasonable is to count the homes or structures
in the potential blast radius. But the federal formula only
considers a radius of 660' from the centerline. The problem
here is that in several catastrophic failures (San Bruno CA,
Appomattox VA, Cleburne TX), the blast radius was far over
that: ~1,000 to ~1,400 ft.

Alternate MAOP

All metal pipelines corrode over time. Since pipeline thickness
is a function of Barlow's Formula for determining the Max Allowable
Operating Pressure, then a pipeline's MAOP should decrease over
time. However, PHMSA has bent to industry "pressure" and has
implemented a scientifically dubious scheme to INCREASE MAOP
of aging pipelines.

Gas Constant
(This is an input into the Potential Impact Radius or PIR).

The problem here is that PST and PHMSA both agree
that the PIR formula is way off. I have gathered data from
5 recent catastrophic gas pipeline failures. IN EACH CASE
the actual impact radius exceeded the predicted PIR
by at lease 1.2x (Sissonville) to as much as 2.5x (San Bruno),
over by 595'ft (Cleburne) and a max radius of ~1,400'ft. (Cleburne).

As you can see by this diagram, these errors become inputs to other
variables, so these accumulate.

Bottom Line: People who live near pipelines in rural areas are
placed into jeopardy by federal safety regulations a DOZEN
different ways.

People who live near pipelines in more populated areas are
placed into jeopardy because HCAs are based on an extremely
flawed PIR formula.

The Algonquin Incremental Markets project (AIM) is proposing
a MASSIVE 42" gas pipeline near a nuclear power facility.
They are assessing the risk based on faulty the faulty HCA/PIR
formula.

ALMOST TOO HORRIBLE TO MENTION: during my research
on the AIM pipeline, I discovered there are several existing pipelines
which run into this same facility.

From a risk management standpoint-- this is insane.

--

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